FAQs

14300.7 - General Recording Criteria

Question
Does the new Cal/OSHA regulation use identical criteria for recording
work-related injuries and illnesses ?

Answer
Yes. The new Cal/OSHA regulation requires injuries and illnesses to be
recorded using identical criteria.

Question
How do I decide if a case meets one of more of the general recording criteria?

Answer
A work-related injury or illness must be recorded if it results in one or more of the
following:

death,

days away from work,

restricted work or transfer to another job,

medical treatment beyond first aid,

loss of consciousness,

a significant injury or illness diagnosed by a physician or other
licensed health care professional.

Question
Does the new Cal/OSHA regulation require the recording of minor illnesses
(e.g. a work-related skin rash that does not result in medical treatment)
?

Answer
No. Illnesses are only recordable if they meet one of the general recording
criteria which include days away from work, restricted work, loss of
consciousness, transfer to another job, or medical treatment beyond first
aid or a significant injury or illness diagnosed by a physician or other
licensed health care professional.

Question
How do I record a work-related injury or illness that results in the employee's death?

Answer
By entering a check mark on the Cal/OSHA Log 300 in the space for cases resulting in death.
Additionally, any work-related fatality must be reported to Cal/OSHA within eight (8) hours.

Question
If an employee dies from surgery made necessary by a work-related injury
or illness, is the case recordable ?

Answer
Yes. Also, if the underlying injury or illness was recorded before the
employee’s death, the employer must update the Cal/OSHA Form 300. The information recorded on the less severe outcomes (e.g. days away from
work or restricted work) must be lined-out and then the column indicating
death must be marked.

Question
How do I record a work-related injury or illness that results in days away from work ?

Answer
By entering:

a check mark on the Cal/OSHA Log 300 in the space for cases involving
"days away
form work", and

the number of calendar days away from work in the number of days "away
from work" column.

If the employee is out for an extended period, enter an estimate of the days away. Update when the actual number of days away is known.

Question
Do I count the day on which the injury occurred or the illness began?

Answer
No. Begin counting days "away from work" on the day after the injury or illness
occurred.

Question
If an employee with a work-related injury, requiring days away form work,
is subsequently terminated for drug use based on the results of a
post-accident drug test, how should the case be recorded ?

Answer
The termination is related to the injury; therefore, the number of days
the employee would have been away from work due to the injury must be
estimated and entered on the Cal/OSHA Form 300.

Question
How do I record an injury or illness when a physician or other licensed health care professional recommends that the worker stay at home, but the employee comes to work anyway?

Answer
By marking the days "away from work" column and then entering the number of calendar days
the physician or other licensed health care professional recommended. The days away must be recorded whether the employee follows the recommendation or not;
however, the employee should be encouraged to follow the recommendation of the physician or other licensed health care professional.

If recommendations from two or more physicians or licensed health care professionals are received, make a decision as to which is the most authoritative, and record the case based upon that recommendation.

Question
How do I handle a case when a physician or other licensed health care professional recommends that the worker return to work, but the employee stays at home anyway?

Answer
End the count of days away from work on the date the physician or other licensed health care professional recommends that the employee return to work.

Question
How do I count weekends, holidays, or other days the employee would not have worked anyway?

Answer
Count the number of calendar days the employee was unable to work as a result of the injury or illness, regardless of whether or not the employee was scheduled to work on those day(s).

Weekend days, holidays, vacation days or other days off are included in the total number of days recorded if the employee would not have been able to work on those days because of a work-related injury or illness.

Question
How do I record a case in which a worker is injured or becomes ill on a Friday and reports to work on a Monday, and was not scheduled to work on the weekend?

Answer
Record this case only if a physician or other licensed health care professional indicates that the employee should not have worked (or performed only restricted work) during the weekend. If so record the days away from work or restricted work, and enter the day counts, as appropriate.

Question
How do I record a case in which a worker is injured or becomes ill on the day before scheduled time off such as a holiday, a planned vacation, or a temporary plant closing?

Answer
Record this case only if a physician or other licensed health care professional indicates that the employee should not have worked (or performed only restricted work) during the scheduled time off. If so record the days away from work or restricted work, and enter the day counts, as appropriate.

Question
How do I count the days if an intermittent worker was previously scheduled for days off during a period he or she is assigned limited duty or days away from work for an Injury or illness?

Answer
You must count the number of calendar days the employee was unable to work as a result of the injury or illness, regardless of whether or not the employee was scheduled to work on those day(s). Weekend days, holidays, vacation days or other days off are included in the total number of days recorded if the employee would not have been able to work on those days because of a work-related injury or illness.

Question
Is there a limit to the number of total days away from work I must count?

Answer
Yes, the "cap" is 180 calendar days. Do not keep track if there were more
than 180 calendar days away from work and/or days of job transfer or
restriction. In such cases enter 180 in the "days away from work" column.

Question
The counting cap of 180 calendar days...can that be a combined total of lost workdays and restricted days?

Answer
The employer may stop counting when the total number of days away, restricted or transferred reaches 180.
(Reference: Federal CPL 2-0.131 - Recordkeeping Policies and Procedures Manual, Chapter 2, Para 1.E.)

Question
May I stop counting days if an employee who is away from work because of an injury or illness retires or leaves for reasons unrelated to the injury or illness ?

Answer
Yes, the count can be stopped. However, if the employee leaves due to the injury or illness, the total number of days away or days of restriction/job transfer must be estimated and entered in the day count.

Question
If a case occurs in one year but results in days away during the next calendar year, do I record the case in both years?

Answer
No, record the injury or illness only once for the year in which it occurred. Update the initial log entry later when the day count is known or reaches the 180-day cap.

For the annual summary, estimate the total number of calendar days the employee is expected to be away from work.

Question
How do I record a work-related injury or illness that does not result in death or days away from work, but does result in restricted work or job transfer?

Answer
By checking the "on job transfer or restriction" column and entering the number of restricted or transferred days.

Question
How do I decide if the injury or illness resulted in restricted work?

Answer
Restricted work occurs when, as the result of a work-related injury or illness, the employee is kept from:

performing one or more of the routine functions of the job; or

working the full workday that was scheduled.

Restriction may come from the employer or be based on the recommendations of a physician or other licensed health care professional.

Question
What is meant by "routine functions"?

Answer
Routine functions are those work activities the employee regularly performs at least once per week.

Question
Do I have to record restricted work or a job transfer if it applies only to the day on which the injury occurred or the illness began?

Answer
No.

Question
If a work restriction is recommended, is the injury or illness automatically recordable as a "restricted work" case?

Answer
No, record only if the employee is kept from:

performing one or more routine job functions; or

working the full workday they otherwise would have worked.

Question
How do I record a case where the worker works only for a partial work shift because of a work-related injury or illness?

Answer
As a day of job transfer or restriction. Do not count the day on which the injury occurred or the illness began.

Question
If a worker normally works ten hours a day, but is restricted by an injury
or illness from working more than eight hours per day, is the case
recordable ?

Answer
Yes, if an injury or illness keeps the employee from working the full
workday they would have otherwise been scheduled to work, the case is
recordable as a work restriction.

Question
If the worker produces fewer goods or services due to the injury or illness, but otherwise performs all of their routine functions, is the case considered a restricted work case?

Answer
No, the case is considered restricted work only if the worker is kept from:

performing all of their routine job functions; or

working the full workday they otherwise would have worked.

Question
How do I handle vague recommendations for restrictions (e.g. perform "light duty" or "take it easy for a week”) from a physician or other licensed health care professional ?

Answer
You may ask the individual making the recommendation whether the employee can do all their routine job functions and work a full assigned work shift.

If the answer to both question is "Yes," then the case does not involve a work restriction and does not have to be recorded as such.

If the answer to one or both questions is "No," the case involves restricted work and must be recorded as such.

If additional information can not be obtained, record the injury or illness as a case
involving restricted work.

Question
What do I do if a physician or other licensed health care professional recommends a job restriction meeting Cal/OSHA's definition, but the employee does all of their routine job functions anyway?

Answer
Record it as a restricted work case and ensure that the employee complies with the restrictions. If two or more recommendations are received, make a decision as to which is the most authoritative and record the case based upon that recommendation.

Question
How do I decide if an injury or illness involved a transfer to another job?

Answer
If the employee is assigned to a job other than their regular job for part
of the day, the case involves transfer to another job. Exclude the
day on which the injury or illness occurred.

Question
Is an employer subject to a possible citation if an employee fails to
follow a recommended work restriction by a physician or other licensed
health care professional?

Answer
No. Section 14300.7 (b)(4)(H) of the new Cal/OSHA recordkeeping regulation
states "the employer should ensure that the employee complies with a
recommended work restriction". However, this language is advisory
only and does not impose and enforceable duty on
employers to ensure that employees comply with recommended restrictions.

Question
Are transfers to another job recorded in the same way as restricted work cases?

Answer
Yes, both are recorded in the same box on the Cal/OSHA Form 300.

Question
How do I count days of job transfer or restriction?

Answer
The same way you count days away from work. The only difference is that if the employee is assigned:

permanently to a job that has been modified or permanently changed (to
eliminate the routine functions the employee was restricted from), stop day count when the modification or change is made permanent,
but count at least one day of restricted work or job transfer for such cases.

Question
How long must a employee be assigned to a modified or changed job before
the assignment can be considered “permanent”?

Answer
For the remainder of the employee’s career. The assignment is considered
temporary if the employee is expected to return to their former job duties
at a future date. If the restriction or transfer is permanent when first
ordered, at least one day of restriction or job transfer must be recorded
on the Cal/OSHA Form 300.

Question
How do I record an injury or illness that involves medical treatment beyond first aid?

Answer
Enter a check mark in column J where the employee received medical treatment but remained at work, if the following are not involved:

death, or

one or more days; away from work, of restricted work, or of job transfer.

Question
What is the definition of medical treatment?

Answer
“Medical treatment” means the management and care of a patient to combat disease or disorder.
It does not include:

visits to a physician or other licensed health care professional solely
for observation/counseling, or

diagnostic procedures (i.e. x-rays and blood tests), or

the administration of prescription medications used solely for diagnostic purposes (e.g., eye drops to dilate pupils), or

"first aid" as defined in paragraph (b)(5)(B) of the Cal/OSHA recordkeeping regulation.

Question
What is "first aid"?

Answer
Using a nonprescription medication at nonprescription strength.

For medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping
purposes.

Administering tetanus immunizations.

Hepatitis B and rabies vaccines are prescription drugs and considered medical treatment. Only
tetanus immunization vaccine qualifies as first aid and all other vaccinations are considered medical treatment when given in response to a
blood borne exposure incident.

Cleaning, flushing or soaking wounds on the surface of the skin; and
Using hot or cold therapy;

Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc.;

Devices with rigid stays or other systems designed to immobilize body parts are considered medical treatment for recordkeeping
purposes.

Using wound coverings such as bandages, butterflies, Band- Aids (Trade Mark) or Steri-Strips (Trade Mark) are considered "first aid."

All wound closing devices (e.g. surgical glue, sutures, staples, etc.) are considered medical treatment because they are not included on the first aid list.

Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister;

Using eye patches;

Removing foreign bodies from the eye using only irrigation or a cotton swab;

Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means;

Using finger guards;

Using massages (physical therapy or chiropractic treatment are considered medical treatment for
recordkeeping purposes);

Drinking fluids for relief of heat stress.

Question
Are prophylactic treatments recordable if they involve medications given
for the prevention of complications i.e. antibiotics for the prevention of
infection or injection of vaccines?

Answer
Section 14300.7 provides a complete list of all treatments considered “first aid”
for purposes of Article 2 and states (in part) that first aid includes
“administering tetanus immunizations (other immunizations, such as Hepatitis B
vaccine or rabies vaccine, are considered medical treatment)”. All other vaccines
given for the purpose of treatment would fall under medical treatment and are
recordable.

Question
What are some “other simple means” of first aid for removing splinters or
foreign material from areas other than the eye?

Answer
In addition to using irrigation, tweezers or cotton swabs, “other simple
means” could include methods which are reasonable comparable to those
listed such as using needles, pins or small tools to extract splinters.

Question
”Drinking fluids for relief of heat stress” is listed as first aid.
Does first aid include administering intravenous (IV) fluids?

Question
For medications available in both prescription and non-prescription
strength, how can the prescription strength be determined ?

Answer
Prescription strength is measure by how much of the therapeutic agent is to
be taken at one time in a single dose. Information on
prescription-strength dosages may be obtained from:

United States Food and Drug Administration

Pharmacists, Physicians

Other licensed health care professionals

Single dosages considered prescription strength for some over-the -counter
drugs include:

Ibuprofen (e.g. Advil) - greater than 467 mg

Naproxen Sodium (e.g. Aleve) greater than 220 mg

Diphenhydramine (e.g. Benadryl) - greater than 50 mg

Ketoprofen (e.g. Orudus KT TM) - greater than 25 mg

Question
Are any other procedures included in first aid?

Answer
No, this is a complete list of all treatments considered first aid.

Question
Does the professional status of the person providing the treatment have any effect on what is considered first aid or medical treatment?

Answer
No, Cal/OSHA considers the treatments listed to be first aid regardless of the professional status of the person providing the treatment. If these treatments are provided by a physician or other licensed health care professional, they are still considered first aid. Like wise treatment beyond first aid is considered to be medical treatment even when provided by someone other than a physician or other licensed health care professional.

Question
If an employee is exposed to a chemical substance at work and oxygen is
administered solely as a precautionary measure, is the case recordable ?

Answer
No, if the oxygen is administered only as a precautionary measure to an
employee who does not exhibit any symptoms of the exposure the case is not
recordable. If the exposed employee exhibits any symptoms from the
exposure and the oxygen is administered in response to these symptoms, the
case recordable.

Question
If an employee is exposed to chlorine or some other substance at work
and oxygen is administered as a precautionary measure, is the case recordable?

Answer
If oxygen is administered as a purely precautionary measure to an employee who
does not exhibit any symptoms of an injury or illness, the case is not recordable.
If the employee exposed to a substance exhibits symptoms of an injury or illness,
and is given oxygen as treatment then the case is recordable. (Reference:
Federal CPL 2-0.131 - Recordkeeping Policies and Procedures Manual, question 7-15)

Question
Is every work-related injury or illness case involving a loss of consciousness recordable?

Answer
Yes, you must record a work-related injury or illness if the worker becomes unconscious, regardless of the length of time the employee remains unconscious.

Question
What are "significant" work-related cases that must be recorded at the time of the initial diagnosis (by a physician or other licensed health care professional) even if medical treatment or work restrictions are not recommended or are postponed ?

Answer
Work-related cancer, chronic irreversible disease, (e.g. byssinosis, silicosis),
fractured or cracked bones (e.g. toes or ribs), or a punctured eardrum must be recorded even if they don’t
involve:

death, days away from work, restricted work/job transfer,

medical treatment beyond first aid, or loss of consciousness

Question
An employee hurts one arm and is told by a physician not to use that arm for one
week. The employee is still able to perform all of the routine job functions with the other arm at a slower pace. Is this considered restricted work?

Answer
No. If the employee is able to perform all of the routine job functions (activities normally performed at least once per week) the case does not involve restricted work. Loss of productivity is not considered restricted work.

Question
Does the size or degree of a work- related burn determine recordability?

Answer
No. If work-related, small and large first, second, or third degree bums
must be recorded if they meet the general recording criteria (e.g. days
away from work, work restrictions, medical treatment etc).